Purpose

This Corrective Action Plan documents and defines a high-level, multi-year Plan for developing, rolling out and scaling up the digital accessibility program at University of Nevada, Reno (“University”).

This Corrective Action Plan and the resulting digital accessibility program will help the University comply with applicable accessibility regulations that cover a variety of technology systems offered or managed by the University.

This Corrective Action Plan was developed after performing discovery activities that allowed the University to gain an understanding of (i) the systems that fall under the scope of the accessibility requirements; (ii) the current level of compliance of those systems with key accessibility standards; and (iii) the relative value of addressing individual systems, components and web pages for compliance based on traffic and system use.

The audience for this Corrective Action Plan includes the Department of Education Office for Civil Rights and all members of the University of Nevada, Reno community.

Context for this Corrective Action Plan

Applicable Accessibility Regulations, Policies & Standards

Below is a list of the relevant regulations, rule-making activities and source statutes that are applicable to the University's business and operations.

Americans with Disabilities Act of 1990 (ADA) Title II - ADA Title II applies to State and local government entities and educational institutions, and, in subtitle A, protects qualified individuals with disabilities from discrimination on the basis of disability in services, programs, and activities provided by State and local government entities and public entities, including universities. Title II extends the prohibition on discrimination established by section 504 of the Rehabilitation Act of 1973, as amended, 29 U.S.C. 794, to all activities of State and local governments as well as educational institutions regardless of whether these entities receive Federal financial assistance. Reference is 28 CFR Part 35.

Americans with Disabilities Act of 1990 (ADA) Title III - ADA Title III prohibits discrimination on the basis of disability in the activities of places of public accommodations (businesses that are generally open to the public which include institutions of higher education).

Section 508 of the Rehabilitation Act of 1973, as amended (Section 508) - Section 508 of the Rehabilitation Act requires any electronic information that is developed, procured, maintained or used by the federal government, and by extension, entities that receive Federal financial assistance, to be accessible to persons with disabilities. Additionally, the Section 508 refresh standards, C301- 302 (Chapter 3 Functional Performance Criteria) is tied to Functional Performance Criteria. Federal Information and Communication Technology Standards and Guidelines (ICT Refresh) are codified in the Code of Federal Regulations. ( 36 CFR 1194).

There are also several other acts and governing accessibility guidelines that need to be considered including:

21st Century Communications and Video Accessibility Act (CVAA) - The CVAA updates federal communications law to increase the access of persons with disabilities to modern communications. The CVAA makes sure that accessibility laws enacted in the 1980s and 1990s are brought up to date with 21st century technologies, including new digital, broadband, and mobile innovations.

W3C Web Content Accessibility Guidelines (WCAG) 2.0 - The Web Content Accessibility Guidelines, published by the World Wide Web Consortium (W3C), are the most widely known and adopted web accessibility standards. While the WCAG applies to web based content such as HTML pages, SVG, Flash, PDF, Silverlight, mobile websites and other web technologies — the standards are applied, in the ICT Refresh (36 CFR 1194) to other technologies including software, native mobile apps, videos and electronic documents. Informative documentation provides guidance on applying WCAG to non-web Information and Communication Technologies (ICT)

Technology Systems Covered

Information and Communication Technology (ICT) is defined as technology, any equipment or interconnected system or subsystem of equipment that is used in the creation, conversion, or duplication of data or information employed in support of the University's Mission and Core Themes.

Organizational Impact

Based on the systems referenced above, all of the University is impacted and it must implement processes to ensure compliance with the applicable accessibility regulations.

Digital Accessibility Policy Artifacts

Accessibility Policy

The University has developed, finalized and communicated a policy to address accessibility that defines the core components of its approach to digital accessibility. This overarching University of Nevada, Reno ICT Accessibility Policy establishes the central direction of the institution and is referenced in other Information and Communication Technology (ICT) plans, policies and procedures.

Accessibility Statement

The University has published a public-facing Commitment to Accessibility statement on its website regarding its non-discrimination and ICT accessibility practices, and includes methods to contact the University's web team, the University's Equal Opportunity and Title IX Office and the U.S. Department of Education Office for Civil Rights with questions, complaints or other requests.

Accessibility Roles and Responsibilities

The Office of the Provost oversees the implementation of and compliance with the ICT Accessibility Policy. The Executive Vice President & Provost, or designee, has appointed a standing ICT Accessibility Committee to coordinate those efforts. Technology accessibility is an institution-wide responsibility.

Each college, administrative unit, faculty member, and employee is responsible to ensure compliance and, if notified of non-compliance, is required to remediate.

Accessibility Procurement & Contracting Procedure

The University has developed an Accessibility Procurement Policy to ensure the Accessibility Policy is followed throughout the procurement process. This policy includes guidance on how roles involved in procurement and contracting should do the following:

Provide accessibility requirements in requests for proposals (RFPs) and other solicitations, and inform vendors of the University's Accessibility Policy and accessibility-related requirements.

Collect claims of compliance and other documents from vendor as part of acquisition process.

Perform analysis of vendor solutions for accessibility, as included in vendor responses and proposals.

Remediation of Digital Assets

The University will conduct another audit of web content and functionality to validate the violations were properly remediated.

Pursuant to the Resolution Agreement, the University has developed the following Information Communications Technology (ICT) Corrective Action Plan based on input from stakeholders and an analysis by Level Access. This Corrective Action Plan includes priorities and a schedule for making ICT accessible, training programs and communication initiative.

The plan below represents the University's priorities, strategies and schedule, according to the Resolution Agreement between the University of Nevada, Reno and the Office for Civil Rights.

Digital Asset Remediation Plan Background

Assurances of Nondiscrimination. The university hereby reaffirms its commitment to ensure that people with disabilities have an opportunity equal to that of their nondisabled peers to participate in the university's programs, benefits, and services, including those delivered through electronic and information technology, except where doing so would impose an undue burden or create a fundamental alteration.

Proposed Corrective Action Plan. Simultaneously with the submission of the Audit, the university will submit to OCR for its review and approval a proposed Corrective Action Plan to address all inaccessible content and functionality identified during the university's Audit. The proposed Corrective Action Plan will set out a detailed schedule for addressing problems, with all corrective actions to be completed within 24 months of the date OCR approved the Corrective Action Plan.

In its Corrective Action Plan, the university will acknowledge that if all inaccessible content and functionality identified during the Audit is not removed or made accessible on a timely basis, the university will be in violation of this agreement, Section 504, and Title II, and OCR may initiate administrative enforcement or judicial proceedings to enforce the specific terms and obligations of this agreement.

Within 30 calendar days of receiving OCR's approval of the proposed Corrective Action Plan, the university will officially adopt and implement the Corrective Action Plan.

The University has undertaken drafting of this proposed Corrective Action Plan in good faith and with full intention of complying promptly and completely with the Resolution Agreement reached with OCR, including time limitations contained therein. Given the complexity of this project, the University reserves the right to request additional time from OCR, should full and complete compliance require any additional time to fully implement the planned redesign and rebuilding of the website.

Document Glossary

The following definitions describe the individuals, units, offices, and committees responsible for executing the Corrective Action Plan.

Accessibility Liaisons: A faculty or staff member designated as the accessibility content person within their division, college, department or unit

Business Purchasing Center: The office that serves the purchasing and contracting needs of the University

Content Creators: Any individual that creates content on behalf of the University

Content Management System (CMS): The system used to create, edit, and publish content on www.unr.edu/

Disability Resource Center (DRC): The office that ensures students with disabilities have equal access to participate in, contribute to, and benefit from all University programs

ICT Scholarly Communication Sub-Committee: A committee comprised of academic faculty members that participates in accessibility conversations and issues related to scholarly communications and research and works to identify processes to ensure the accessibility of this content

ICT Software Accessibility Review Sub-Committee: A committee that reviews and manages accessibility processes for software acquisition for the University

Office of Information Technology (OIT): The department that maintains the University's information technology systems, such as networking, applications, and information security

Office of Marketing & Communications (MarCom): The department that serves as the primary owners of the University's Content Management System, and central marketing and communications efforts for the University

Teaching & Learning Technologies (TLT): The department that provides support for instructional design, classroom technology, and instructional technologies, including the Learning Management System (LMS)

Corrective Action Plan

*Activities & Tasks with a planned completion date in BOLD have been completed

1.0 - General: Policies, Procedures, Communication, and Training

Table 1: Accessibility Policies and Procedures

Activities and Tasks

Start Date

Planned Completion Date

Responsible Parties

Develop accessibility policies and procedures

7/1/2015

7/1/2017

ICT Committee

Publish commitment to accessibility statement on website

3/1/2017

3/1/2017

ICT Committee

Publish accessibility policies and procedures on website

7/1/2017

7/1/2017

ICT Committee

Table 2: Accessibility Communication

Activities and Tasks

Start Date

Planned Completion Date

Responsible Parties

Meet with UNR Communication Team to develop a communication plan to inform constituents of the intent, scope and progress regarding the Universities accessibility initiatives.

Develop a training plan and course material for basic web accessibility training for all appropriate personnel

2/9/2017

3/1/2017

Teaching & Learning Technologies (TLT)

Training sessions are offered

3/20/2017

Ongoing

Teaching & Learning Technologies (TLT)

Reporting to OCR regarding training activities

3/14/17

3/14/17

12/31/17

Ongoing

Teaching & Learning Technologies (TLT)

2.0 - Web Accessibility

Using automated accessibility tools such as the SiteImprove Intelligence Platform, the Level Access AMP application, as well as manual testing, the University identified many of the commonly made accessibility issues. Based on the nature of the barriers, the outdated web governance, and the Benchmarks for Accessibility requirements, the University has determined a complete redesign and rebuild of the website, www.unr.edu, would be more cost effective and result in the most accessible website.

Table 4: Web Accessibility Overview

Activities and Tasks

Start Date

Planned Completion Date

Responsible Parties

All web content created by or on behalf of the University will be accessible according to WCAG 2.0 level AA

7/1/2017

Within 24 months from CAP acceptance by OCR

Domain Owners Accessibility Liaisons MarCom

Identify and develop web property (URL) registry of all known University domains and subdomains

11/1/2017

3/31/2018

MarCom Accessibility Liaisons OIT

Table 5: Content Management System Web Content (www.unr.edu)

Activities and Tasks

Start Date

Planned Completion Date

Responsible Parties

Identify HTML content to carry forward in new site build and prioritize remediation efforts prior to migration

11/1/2017

6/30/2018

MarCom Accessibility Liaisons

Remove content from the site that will not be carried forward into new design

6/30/2018

6/30/2019

MarCom

Create inventory of documents related to each web property in the domain registry

2/1/2018

6/30/2018

Accessibility Liaisons MarCom

Identify documents to remediate and carry forward into the new web design

2/1/2018

6/30/2018

Accessibility Liaisons

Remove documents from the site that will not be carried forward into new design

7/1/2018

6/30/2019

MarCom

Remediate CMS-based documents that have accessibility issues

7/1/2018

6/30/2019

Accessibility Liaisons

Create inventory of CMS-based embedded multimedia (e.g. videos)

3/1/2018

5/31/2018

MarCom

Identify CMS-based embedded multimedia to remediate and carry forward into new website build

6/1/2018

6/30/2018

MarCom

Remove non-accessible embedded multimedia that will not be carried into the new web design

Accessibility training sessions were expanded, redesigned, and offered with increased frequency. Materials were created to support faculty creation of accessible materials as well in 2017. (See Addendum: General Accessibility Trainings)

3/20/2017

Ongoing

Teaching & Learning Technologies (TLT)

Require faculty to attend Basic Web Accessibility training, annually

3/20/2017

Ongoing

Provost Academic Faculty

Teaching & Learning Technologies (TLT)

Implement Blackboard's Ally software to ensure more accessible course content is available to students, offer additional feedback to faculty regarding their materials, and provide analytics to administration

11/1/2017

11/1/2017

Teaching & Learning Technologies (TLT) OIT

Ensure accessible live chat and discussion board functions in the LMS

In 2015 and 2017, the discussion board functionality was found to be accessible according to WCAG 2.0 AA and the company's VPAT. Our 2017 audit confirmed this functionality.

4/2/2015

10/3/2017

Teaching & Learning Technologies (TLT)

Develop accommodations for the web conferencing platform built into the LMS

9/7/2016

1/5/2017

Teaching & Learning Technologies (TLT) DRC

Develop and conduct training on how to create and use accessible material in the LMS

All instructional materials located outside of the LMS will be accessible in accordance with University policy.

1/1/2018

12/31/2018

Academic Faculty

Instructional software applications used in courses will be accessible in accordance with university policy.

1/1/2018

12/31/2018

Academic Faculty

Procedures have been established for faculty to request accessibility review of instructional software applications.

4/1/2015

4/1/2015

4/1/2017 (Updated)

ICT Software Accessibility Review Subcommittee OIT

University Libraries

Using automated accessibility tools such as SiteImprove Intelligence Platform, the University Libraries identified many of the commonly made accessibility issues. The University Libraries has determined a complete redesign and rebuild of the Libraries' web presence (e.g. library.unr.edu; guides.library.unr.edu) would be the most efficient way to achieve a more usable and accessible web presence.

Table 9: Library Website and Services Accessibility

Activities and Tasks

Start Date

Planned Completion Date

Responsible Parties

Accessibility Liaison submit new sites to be scanned by SiteImprove

2/14/2018

Ongoing

University Libraries

The University Libraries' websites, documents and electronic media will be accessible according to WCAG 2.0 Level AA

2/14/2018

Within 24 months from CAP acceptance by OCR

University Libraries

Identify HTML content to carry forward in new site build and prioritize remediation efforts prior to migration

2/14/2018

Within 24 months from CAP acceptance by OCR

University Libraries

Remove content from the site that will not be carried forward into new design

2/14/2018

Within 24 months from CAP acceptance by OCR

University Libraries

Create inventory of documents

2/14/2018

Within 24 months from CAP acceptance by OCR

University Libraries

Identify documents to remediate and carry forward into the new web design

2/14/2018

Within 24 months from CAP acceptance by OCR

University Libraries

Remove documents from the site that will not be carried forward into new design

2/14/2018

Within 24 months from CAP acceptance by OCR

University Libraries

Remediate documents that have accessibility issues

2/14/2018

Within 24 months from CAP acceptance by OCR

University Libraries

Create inventory of embedded multimedia (e.g. videos)

2/14/2018

Within 24 months from CAP acceptance by OCR

University Libraries

Identify embedded multimedia to remediate and carry forward into new website build

2/14/2018

Within 24 months from CAP acceptance by OCR

University Libraries

Remove non-accessible embedded multimedia that will not be carried into the new web design

2/14/2018

Within 24 months from CAP acceptance by OCR

University Libraries

Remediate embedded multimedia that have accessibility issues

2/14/2018

Within 24 months from CAP acceptance by OCR

University Libraries

Work with Libraries staff to ensure that scholarly databases are accessible

8/1/2015

Ongoing

University Libraries

4.0 - Documents

Table 10: Document Accessibility

Activities and Tasks

Start Date

Planned Completion Date

Responsible Parties

Create and publish instructional materials on how to create accessible documents. These materials will be reviewed and revised as standards and file formats evolve.

10/16/2017

Ongoing

Teaching & Learning Technologies (TLT)

Establish and publish best practices on accessible PDF documents used for instruction. These materials will be reviewed and revised as standards and file formats evolve.

10/16/2017

Ongoing

Teaching & Learning Technologies (TLT)

Develop and implement training sessions on how to create accessible PDF documents.

10/16/2017

Ongoing

Teaching & Learning Technologies (TLT)

Develop and implement strategies for producing accessible scientific and mathematical documents. Teaching & Learning Technologies (TLT) will continue to work with the DRC to establish best practices for these documents.

5.0 - Electronic Media Accessibility

Table 11: Video Accessibility

Activities and Tasks

Start Date

Planned Completion Date

Responsible Parties

All videos (professionally or internally produced) used in courses and shared on campus websites or video storage sites will be captioned according to recommended Described and Captioned Media Program (DCMP) standards

12/8/2015

1/1/2019

Teaching & Learning Technologies (TLT) MarCom

Faculty Members

Implement policy, effective January 1, 2018, requiring all new instructional videos to be captioned.

Students may request that recordings of course sessions and presentations created for and during a course, and in use only during that course, be captioned

Prior to 2012

Ongoing

Teaching & Learning Technologies (TLT) DRC

Establish procedures for students to request that course recording videos be captioned

NOTE: Videos for courses that have been identified by the DRC are automatically captioned. Teaching & Learning Technologies (TLT) also can process more immediate requests that might come through the DRC as well. This process was established in 2015 and has been refined in 2017.

12/8/2015

Ongoing

Teaching & Learning Technologies (TLT) DRC

Share this information each semester with students with disabilities through Disability Resource Center (DRC)

Prior to 2012

Ongoing

DRC

6.0 - Accessibility Reviews

Table 12: Accessibility Review and Audits

Activities and Tasks

Start Date

Planned Completion Date

Responsible Parties

Obtain SiteImprove license for unlimited sites and pages.

4/1/2017

11/1/2017

MarCom OIT

Conduct reviews and internal audits on quarterly basis.

3/1/2018

Ongoing

ICT Audit Sub-Committee

Contact site owners with review details.

3/1/2018

Ongoing

ICT Audit Sub-Committee

Review Ally reports to monitor progress on instructional materials in the LMS.

3/1/2018

Ongoing

ICT Audit Sub-Committee Teaching & Learning Technologies (TLT)

Review remediated results on a quarterly basis and notify site owners.

3/1/2018

Ongoing

ICT Audit Sub-Committee

Report inaccessible content to provost for enforcement quarterly.

6/1/2018

Ongoing

ICT Audit Sub-Committee

Accessibility Training Plan

The University has developed a training plan to ensure the ICT Accessibility Policy is put into practice during the digital media creation process. The University will provide regularly scheduled face-to-face training opportunities and develop an online version of the training. The training plan includes the following:

All employees who create, edit or publish content to the web are expected to attend Basic Web Accessibility Training on an annual basis.

The training will provide best practices on how to make content accessible in accordance with our standards (WCAG 2.0 AA).

All training attendance will be documented.

Training reports will be provided to the Department of Education, Office of Civil Rights (OCR) on an annual basis, until such time as the OCR closes its monitoring of our resolution agreement.

ICT Accessibility Implementation Plan

In addition to the specific details for remediation of digital assets identified in the external audit of 2017 provided in the section titled, “Remediation of Digital Assets,” the University is developing an internal, overarching ICT Accessibility Implementation Plan for adoption to address ICT not otherwise covered in the external audit.

The Accessibility Implementation Plan will also include sufficient quality assurance procedures including setting up a system of testing and accountability to maintain the accessibility of all online content and functionality on an ongoing basis. This also applies to online content and functionality developed by, maintained by, or offered through a third party vendor or through the use of open sources, and includes setting up systems of accountability and verifying claims of accessibility by vendors or open sources.

Monitor for Accessibility Compliance

The University has purchased a license to the SiteImprove Intelligence Platform which allows for the collection of compliance violations, basic reporting and automated weekly scans of all registered web properties. SiteImprove also allows the University to analyze compliance by websites and responsible parties. The Accessibility Issues by Sites report will be used by the ICT Audit Sub-Committee to determine accessibility compliance progress on a quarterly basis. The report can also be used to communicate compliance outcomes to internal stakeholders and regulatory authorities as required.

The University has also purchased a license to the Ally Canvas plugin which allows for the identification and reporting on accessibility compliance of instructional materials located in the LMS.

In addition, the University currently manually tests software with assistive technology for accessibility compliance. The ICT Committee currently has an ad-hoc procedure for manually testing websites and web content.

Community Outreach

University Surveys

The University conducted outreach surveys each semester starting in the Fall of 2015 and spanning through the Spring of 2017. The summary results of those surveys are documented below. Each question that was posed during the survey are followed by statistics summarized from the survey periods:

I was able to access my coursework posted through the University's Learning Management System (WebCampus).

From the Fall 2015 to the Spring 2017, there has been a 19.5% increase in Strongly Agree responses. There are no disagree or strongly disagree responses where previously there were 3.1% and 2% respectively.

I was able to use the University's computer labs to complete research and assignments.

From the Fall 2015 to the Spring 2017, there has been a 12% increase in Strongly Agree responses. There are no disagree responses where previously there were 4.1%.

I was able to successfully participate in my course using Classroom Response Systems (Clickers).

From the Fall 2015 to the Spring 2017, there has been a 6.7% increase in Strongly Agree responses. There are no disagree responses where previously there were 4.1%.

I was able to effectively participate with my class using on-line classwork systems (My Mathlab, Pearson, etc.).

From the Fall 2015 to the Spring 2017, there has been an 18.5% increase in Strongly Agree responses. There are no disagree or strongly disagree responses where previously there were 5.1% and 3% respectively.

I was able to successfully participate in all course work through the use of captioned videos (class lecture and WebCampus).

From the Fall 2015 to the Spring 2017, there has been a 19.8% increase in Strongly Agree responses. There are no disagree or strongly disagree responses where previously there were 7.1% and 2% respectively.

I was able to easily add money to my WolfCard.

From the Fall 2015 through the Spring 2017, there has been a 2.3% increase in Strongly Agree responses.

Addendum

Is your course content on WebCampus accessible? In this workshop, you will learn how to create or convert existing documents (images, Microsoft Word and PowerPoint) on your WebCampus course into accessible formats.

11/18/2014 -

02/13/2017

Basic Web Accessibility Training

Learn why and how to create accessible web-based materials. This workshop will overview the need for accessible content, current regulations related to accessibility, and tips for providing an equitable experience for all users.

3/1/2017 - Ongoing

Creating Accessible Office Documents

This is hands-on follow up to Basic Web Accessibility for people who create content via Office, PowerPoint, Excel, and Publisher. Is your course content in WebCampus accessible? In this workshop, you will learn how to create or convert Microsoft Office documents (Word, PowerPoint, Excel, and Publisher) into accessible formats.

NOTE: Participants should have an understanding of basic web accessibility or should attend a workshop prior to attending this training.

9/18/2017- Ongoing

PDF Remediation for Accessibility

Learn how to use Adobe Acrobat Pro to check PDFs and remediate for accessibility. This 2-hour course will cover the basics of setting up accessibility tools and views, performing accessibility checks, and remediating potential problems by tagging documents to ensure proper reflow and reading order, structuring tables & lists, adding alternative text for images and formulas, identifying hyperlinks, creating bookmarks, and more.

10/16/2017- Ongoing

Hands-on with Ally - Canvas Accessibility

Curious about how Ally works and how to make your course more accessible? Come to the hands-on ally training to learn about features for faculty and students. After an overview, time is allotted for guidance as you work on examples from your specific course materials.